1. HINDUSTAN PETROLEUM CORPORATION LIMITED
WHISTLE BLOWER POLICY
1. Preface:
· The Corporation believes in conducting its business in a fair and transparent
manner by adopting highest standards of professionalism, honesty, integrity and
ethical behavior. As such the Corporation endeavors to work against corruption
in all its forms including demand and acceptance of illegal gratification and abuse
of official position with a view to obtain pecuniary advantage for self or any other
person.
· Towards this end, the Corporation has framed and adopted Conduct, Discipline
and Appeal rules and Standing Orders which govern the conduct of Management
employees and workmen. The Vigilance dept. of the Corporation is also
empowered to initiate investigations on its own and act on complaints received
from public / employees, with regard to violation of Corporation’s rules and
procedures in the conduct of business.
· Any actual or potential violation of the Corporation’s rules, regulations and
policy governing the conduct of business is a matter of serious concern for the
Corporation. The Corporation is therefore committed to developing a culture
where it is safe for employees - officers and workmen to raise concerns about
instances if any, where such rules, regulations and policy are not being followed
in furtherance of business.
· Clause 49 of the Listing Agreement between listed companies and the Stock
Exchanges, inter-alia, provides as a non mandatory requirement for all listed
companies to establish a mechanism called “whistle blower policy” for employees
to report to the management concerns about unethical behavior, actual or
suspected fraud or violation of the company’s code of conduct or ethics policy.
This mechanism is also required to provide for adequate safeguards against
victimization of employees, who avail of the mechanism and for direct access to
the Chairman of the Audit Committee.
· The objective of this policy is to build and strengthen a culture of transparency
and trust in the organization and to provide employees – officers and workmen
with a framework / procedure for responsible and secure reporting of improper
activities (whistle blowing) and to protect employees wishing to raise a concern
2. about improper activity / serious irregularities within the Corporation.
· The policy does not absolve employees - officers / workmen from their duty of
confidentiality in the course of their work. It is also not a route for taking up
personal grievance.
2. Definitions:
1. “Corporation” means Hindustan Petroleum Corporation Limited.
2. “Audit Committee” means the Audit Committee constituted by the Board of
Directors of the Company in accordance with Section 292A of the Companies
Act, 1956 and read with Clause 49 of the Listing Agreement with the Stock
Exchanges.
3. “Competent Authority” means the Chairman & Managing Director of the
Corporation and will include any person(s) to whom he may delegate any of his
powers as the Competent Authority under this policy from time to time.
4. “Employee” means a Management employee (officer) as defined in the
Conduct, Discipline and Appeal rules applicable to Management employees and
permanent workmen as defined in the applicable Standing Orders for Marketing
establishments / Mumbai Refinery and Visakh Refinery of the Corporation. and
includes a person on deputation to the Corporation.
5. “Improper Activity” means any activity by an employee of the Corporation that
is undertaken in performance of his or her official duty, whether or not that act is
within the scope of his or her employment, and that is in violation of any law or
the rules of conduct applicable to the employee, including but not limited to
abuse of authority, breach of contract, manipulation of company data, pilferage of
confidential / proprietary information, criminal offence, corruption, bribery, theft,
conversion or misuse of the Corporation’s property, fraudulent claim, fraud or
willful omission to perform the duty, or that is economically wasteful or involving
gross misconduct, incompetence or gross inefficiency and any other unethical
biased favoured or imprudent act.
Activities which have no nexus to the working of the Corporation and are purely
of personal nature are specifically excluded from the definition of Improper
Activity.
3. 6. “Investigators” mean those persons authorized, appointed, consulted or
approached by the Chairman & Managing Director / Competent Authority in
connection with conducting investigation into a protected disclosure and includes
the Auditors of the Corporation.
7. “Protected Disclosure” means any communication made in good faith that
discloses or demonstrates information that may evidence unethical or “Improper
Activity”.
8. “Service Rules” means the Conduct, Discipline and Appeal rules in case of
Management employees and the applicable Standing Orders in case of
employees other than Management employees.
9. “Subject” means an employee - officer / workmen against or in relation to whom
a Protected Disclosure has been made or evidence gathered during the course
of an investigation.
10. “Whistle Blower” means and Employee making a Protected Disclosure under
this policy.
3. Eligibility:
All employees of the Corporation are eligible to make “Protected Disclosures”.
4. Guiding Principles:
1. Protected disclosures are acted upon in a time bound manner.
2. Complete confidentiality of the Whistle Blower is maintained
3. The Whistle Blower and / or the person(s) processing the Protected
Disclosure are not subjected to victimization.
4. Evidence of the Protected Disclosure is not concealed and appropriate action
including disciplinary action is taken in case of attempts to conceal or destroy
evidence.
5. Subject of the Protected Disclosure i.e person against or in relation to whom a
protected disclosure has been made, is provided an opportunity of being heard.
